The California Air Resources Board is expected to administer the same lethal dose to the ethanol industry as it meted out to the electric car some ten years ago In a last-minute flurry of appeal more reminiscent of the battle to save Caryl Chessman or other condemned prisoners from the gas chamber at San Quentin, biofuels supporters, and in particular friends of ethanol, pelted the California Air Resources Board with last-minute appeals to refrain from including Indirect Land Use Change Analysis in the proposed Low Carbon Fuel Standard until the science is more robust. Critics and supporters of the proposed Indirect Land Use Change analysis have agreed that the science is immature. The question is whether to attribute a penalty to biofuels now, and correct errors in the future, or to delay implementation until a standard model emerges. Critics of ILUC have charged that a tangled web of relationships between oil companies, environmental organizations, consultants and academics has made it impossible for biofuels to get a fair hearing from CARB. They have pointed out that no other fuel has been subjected to penalty based on the indirect consequences of the fuel’s production. From Brent Erickson at BIO came one of the most through critiques of Indirect Land Use Change analysis including an analysis of the rapid evolution of the art, and the different results that teams have seen from the use of the GTAP model. Erickson said in part: “The Board should direct its staff to continue soliciting input from all stakeholders and from the scientific community on appropriate ILUC modeling and reliable data sources, without any fixed commitment to GTAP or the parameters used in GTAP, for a period of up to 2 years….Next time, peer reviews should be completed and posted for public comment before the public comment period on the proposed regulations begins…During the period in which ILUC methodologies are finalized in California, the LCFS regulations should be implemented without ILUC penalties.” BIO also released “ Sustainable Biofuels: a commonsense perspective on California’s approach to biofuels and global land use, ” by industry consultant Jack Sheehan, which can be downloaded here. Sheehan wrote: “The declining land clearing debt estimates in CARB’s GTAP analysis relative to the ?rst published estimates by Searchinger in 2008 re?ect progress being made in the re?nement of the estimates of iLUC impacts, particularly with regard to the types of land affected by the increased demand for biofuels production. The sharply differing estimates between 2008 and 2009 demonstrate how rapidly our understanding the iLUC phenomenon is changing.” The summary of the ILUC draft analysis can be downloaded here . Also, the Huffington Post published an article by Andrew Gumbel, in which the LA-based freelancer writes: “ A few years ago, CARB caved to pressure from the oil and car industries and gave the green light that enabled GM and the rest of the automotive behemoths to “kill” the electric car . Now it is on the brink of performing another disservice to the future of the planet – this time by considering the adoption of an unproven, brand new method of “carbon scoring” different fuel types that happens to discriminate heavily in favor of old-fashioned fossil fuels like oil and gas and penalize biofuels. “CARB’s decision, which has already been drafted and may or may not be made final on the first day of a two-day board meeting in Sacramento today, will be crucial not just to the fight against global warming in California. The means it chooses to determine the carbon intensity of different fuel types is likely to set the standard nationally, if not also globally. So a great deal is at stake. “The methodology is not without its complications, but essentially CARB has two choices. The first is to “carbon score” different fuel types based on their chemistry and means of production alone, the so-called “well to wheels” model known by the acronym GREET which has been used and fully peer-reviewed. “The second choice is to try to throw in considerations of broader economic and geopolitical realities. That’s not a bad idea in and of itself. It’s hard to assess the total environmental cost of importing oil from the Middle East without considering, say, the fuel burned on the tanker that brings it to the United States, or considering the impact of the continuing U.S. military presence in Iraq. The problem with the model being touted by CARB, though, is that it looks at these indirect factors in the context of biofuels only. It factors in the cost of driving ethanol by truck from Iowa to California, but lets oil and gas off the hook completely for comparable factors. “A group of more than 100 scientists specializing in energy and the environment have written both to Governor Schwarzenegger and to Mary Nichols, who chairs CARB, to voice their concerns. “We’re basically talking about increasing the carbon score of some alternative fuels by 40-200% based on dubious economic modeling that is nowhere near ready for prime time, and then to add insult to injury they are not doing the same economic analysis on other eligible fuels in the program or petroleum,” the letter’s lead signatory, Blake Simmons of the Sandia National Laboratory, said in a statement. “This is indefensible from either a scientific or public policy perspective and will ultimately fail.” Gumbel also pointed out that CARB member Dan Sperling, whom Gumbel described as leading the charge against biofuels, was initimately involved in the CARB decision to end the electric car mandate in the 1990s at the behest of opil and car companies. The director of the documentary “who Killed the Electric Car?” described today’s hearing as a “cast reunion”. The CARB hearing today is available via video (or audio only) webcast here . POET CEO Jeff Broin made a last-minute appeal ( full text here) : “The ethanol industry supports an accounting of carbon emissions that includes all direct effects from all fuels, including direct land use change. It does not support the selective inclusion of indirect effects as CARB is proposing. Their proposal unfairly penalizes ethanol for indirect effects without considering the indirect effects of any other fuel. POET is not requesting special preference for our products. We are simply requesting the level playing field promised as part of the LCFS and that CARB hold ethanol to the same carbon accounting standard as petroleum, hydrogen, electricity, and all other fuels.”
